Case Study 8: Windward Trading: Charging a shelf company with money laundering and returning confiscated funds to Kenyan citizens

This case study describes how authorities in Kenya and Jersey worked together to unlock progress in a long-running case involving around USD 3.7 million in corruptly acquired funds.

The money was held in the bank account of the shelf company Windward Trading, which was used to channel corrupt payments relating to power generation in Kenya.

The money had been seized in Jersey since 2011 following a money laundering investigation and subsequent criminal proceedings. Kenyan Ethics and Anti-Corruption Commission (EACC) reasonable grounds to suspect the funds were proceeds of corruption. But the case had stalled due to issues with extraditing the two suspects to Jersey to stand trial.

Proactive informal cooperation was key to building trust between the parties. This helped to break the deadlock, find legal solutions to recover the funds and agree their safe return for the benefit of Kenyan citizens.

The parties mutually agreed that the recovered assets should be used for medical equipment and pandemic relief in Kenya. Crown agents and Amref Health Africa are responsible for disbursing and safeguarding the funds.

A framework agreement signed by the Governments of Kenya, Jersey, Switzerland and the UK was used as a basis for negotiations on the return of the funds.

Open-access licence and acknowledgements

This publication is part of the Basel Institute on Governance Case Study series, ISSN 2813-3900. It is licensed for sharing under a Creative Commons BY-NC-ND 4.0 licence.

The Case Study series offers practitioners insights into interesting and precedent-setting cases involving corruption and asset recovery. Many such cases are drawn from partner countries of the Basel Institute's International Centre for Asset Recovery.

Suggested citation: Marsh, Simon. 2022. “Windward Trading: Charging a shelf company with money laundering and returning confiscated funds to Kenyan citizens." Case Study 8, Basel Institute on Governance. Available at:

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Cover page of case study 8
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Basel Institute on Governance